The Shelter to Housing Continuum (S2HC) project addresses the urgent need to provide more options for those who are homeless – or could potentially experience homelessness – and facilitates transitions to permanent housing for housing-vulnerable Portlanders.
The proposed amendments to City code would allow needed emergency shelters, day storage and hygiene facilities, transitional living facilities, and stable housing for individuals and households with extremely low incomes. It would also improve how the regulatory environment affects for-profit, nonprofit, and public sector shelter and housing providers.
The proposals fall into four categories:
- Traditional sheltering and temporary facilities
- Outdoor shelters and day facilities
- Housing flexibility through group living
- Limited occupancy of a recreational vehicle or a tiny house on wheels on residential property.
These FAQs address important topics about the project and overall proposal.
What is this project about?
The project changes a variety of City codes to help partner agencies (the City-County Joint Office of Homeless Services, Housing Bureau, Bureau of Development Services) and nonprofits (e.g., Central City Concern) provide safe and decent shelter and more affordable housing for those in need during this crisis of homelessness.
Why is this project happening so fast?
- BPS was directed by City Council on Feb. 19, 2019, to undertake this work through Ordinance No. 189387, which extended the City’s State of Housing Emergency to April 4, 2021.
- This project changes City codes to provide most of the same opportunities that the Housing Emergency provided – but on a more permanent basis.
- The COVID-19 pandemic is expected to worsen Portland’s homeless crisis, should more people lose their jobs or rent and mortgage payment moratoria and unemployment benefits expire. Changing the code now allows the City to get in front of this potential increase.
- People who are homeless, living on the streets in tents or vehicles, are suffering. This project makes it easier for the City and shelter providers to replace informal encampments with sanctioned shelters that have onsite services, such as hygiene facilities, garbage collection and, in some cases, wraparound medical, disability, and social services that help people get ready to rent.
Why does the S2HC map show so many new shelters in East Portland?
The Shelter to Housing Continuum proposal includes maps that show where shelters would be allowed, if adopted. These maps show the amount of vacant or underutilized land (by neighborhood) where shelters would be permitted – not where shelters would go. There is more available land in outer East Portland because it has more vacant land and larger parcels. Inner Portland and West Portland neighborhoods have smaller parcels and slightly less vacant land, but these areas have plenty of sites zoned to allow shelters. When it comes to implementation, shelters will be focused where there is greatest need.
What is the difference between “shelter” and “housing”?
Shelter is a community service provided by government agencies or nonprofit corporations to help people experiencing homelessness. A “host” provides shelter and services to a “guest” or “client,” who is supported as they transition to housing.
Housing is residency established under landlord-to-tenant relationship or by ownership. The zoning code categorizes housing as a residential use and shelters as a community service use.
What is considered a “dwelling unit”?
A dwelling unit is a building or a portion of a building that has independent living facilities, including provisions for sleeping, cooking, and sanitation (a bedroom, kitchen and bathroom).
What are “allowed uses” and “conditional uses”?
The zoning code categorizes land uses as allowed, conditional and prohibited. Allowed means a permit can be issued for the use without any public process or hearing. Conditional means that there must be public notice and an opportunity for a hearing. Prohibited means a permit cannot be issued.
Why does the project eliminate the regulation about the number of people allowed to live in a dwelling unit?
- The current definition of Household is outdated and does not reflect the range of living arrangements today.
- This definition is also unenforceable because, in some cases, it relies on proving a blood relationship between household members.
- Other City codes already have limits on the number of people in a building, based on bedrooms and square feet. It is not necessary to also regulate the number of occupants in the zoning code.
How does this project relate to the City’s inclusionary housing rules that require a percentage of affordable units in new apartments and condominiums?
Inclusionary housing (IH) requirements require a percentage of affordable units in new development with more than 19 units. While adjusting group living housing regulations, the project was careful to neither expand nor contract IH requirements. Inclusionary housing requirements do not apply to shelters.
Will shelters be allowed in parks and open space zones? Why or why not?
The current proposal does not allow for shelters to be permanently located in open space zones. This is because:
- Open space (OS) zones often include environmental resources that should not be disturbed.
- Parks and open space have often been purchased with bond money limited to specific purposes or were given to the City with deed restrictions, often stipulating they must be used for parks, recreation or open space purposes, which doesn’t include housing, shelters or other types of development.
- The proposal would, however, allow the temporary siting of shelters in parks and open space for no more than 180 day.
The proposed regulations:
- Expand where shelters are allowed without conditional use.
- Increase allowed number of shelter beds in the CM2 (commercial/mixed use) and CI2 (campus/institutional) zones.
- Clarify that clients may stay longer than 30 days in short-term shelters.
- Add a new path for permitting outdoor village-style shelters so they do not have to be authorized one at a time by Council code waivers.
- Facilitate more rapid opening of seasonal or weather-related temporary facilities.
- Allow day storage and hygiene facilities.
- Allow institutions (such as churches and schools) to provide meal programs, shelter and related services.
What are the three shelter types and how do they differ?
No single shelter type or shelter model can solve this crisis alone. These different types of facilities serve different types of clients.
- Outdoor shelters (new to the Zoning Code with this proposal) are organized groups of tents or other accommodations that do not qualify as buildings. Supporting hygiene, storage and kitchen facilities could be in accompanying buildings. Shelters would be operated by a public agency or a nonprofit. The state of emergency helped us develop alternative outdoor shelter models like the Kenton Women’s Village and the upcoming St. Johns Village. These village-style shelters appeal to people who are more comfortable with smaller and more intimate settings. These communities empower participants to help and care for one another.
- Mass shelters are in buildings but do not provide individual bedrooms. Examples: Laurelwood Center, Harbor of Hope, Willamette Center and Bybee Lakes Hope Center.
- Short-term shelters provide individual bedrooms. Bathrooms or kitchens may be shared or private. Examples: Multnomah County Behavioral Resources Center.
Where will these new outdoor shelters be allowed?
- Smaller shelters would be allowed by right in commercial, multi-dwelling, and employment zones.
- Larger shelters could be permitted as conditional uses.
- There would be a limited allowance with a conditional use review in industrial zones.
- Shelters could also be allowed temporarily or seasonally anywhere – with permission of the landowner – but for no more than 180 days.
- The City also retains flexibility to site temporary shelters anywhere without a conditional use for longer periods of time in response to disasters, such as the COVID-19 emergency or in the aftermath of an earthquake.
Will this project allow people to continue to camp in parks and on sidewalks and along streets?
No. Informal camping remains prohibited, but this prohibition has not been strictly enforced during the COVID-19 emergency. It is unkind to direct campers to leave parks, sidewalks and roadsides unless there is another place they can safely shelter. This project provides more sanctioned alternatives to informal camping.
Why not allow any vacant lot or empty building to be used for shelter?
Many vacant lots and buildings will qualify as shelter sites. But sheltering on any site requires the permission of the landowner, including public landowners like the City of Portland.
Many schools are empty and could provide shelter space; have you considered using those spaces?
Schools are expected to open again in 2021, and this project is about longer term allowances for shelters. On a temporary basis, vacant school buildings could be used for shelters for up to 180 days, with permission of the school board.
Instead of increasing allowances for shelters, why doesn’t the City build more affordable housing?
The City is doing both. Shelter is a “front door” to services that help transition people to housing. This continuum strategy allows more options for the City to meet people experiencing homelessness or housing insecurity where they are and begin a transition to stable housing. In the meantime, City and Metro bond money is being used to build more affordable housing.
Location and staffing of new shelters
Where are existing encampments in the city now?
The dots on this map represent reports received from the community by the City’s Homelessness and Urban Camping Impact Reduction Program between November 2020 and February 2021. These are not “official” City counts; the dots represent “reports of campsites received.” Also, a dot could mean one tent or it could mean 75 structures.
How will the decision be made about where new shelters will be located?
For shelters funded with public dollars, the City of Portland/Multnomah County Joint Office of Homeless Services (JOHS) would make that decision. These decisions are made based on available resources to support any new shelter program for adults, families, youth, and domestic violence survivors, including rental assistance, support services, workforce training and street outreach.
The Joint Office begins with the need it’s trying to fill, e.g., 80 to 120 beds for adults or more space for families seeking shelter. It then looks at the parts of the County where there is an unmet need for shelter. And within those areas, it looks for suitable land use zones.
The Joint Office looks for properties that offer the best combination of size, layout, and condition for use as a shelter. Also important are nearby features, such as regular public transit, community amenities, educational resources, recreational opportunities, and social services. Just like people in permanent housing, shelter participants rely on, and want to live near libraries, transit lines, medical offices, and grocery stores.
Participants also benefit from being close to affordable housing opportunities, as well as educational, employment and social services. Ease of access to those connections is especially important for the growing share of people in shelter who are 55 and older or who have disabling conditions or mobility challenges. Those community connections simply wouldn't be possible if people are sheltered in remote locations far from community.
This thorough process yields very few viable sites. And once one is found, the Joint Office must determine whether the property is actually available, for how long, on what financial terms and ultimately if it is a feasible site for a shelter. Once a shelter site is obtained, the Joint Office then works with an expert shelter operator to run the shelter.
In the past four years, only eight year-round shelter facilities have been built or opened, from the Pearl District, St Johns and Kenton to Lents and Mill Park. Five of those shelters replaced or expanded previously existing programs with high-quality spaces. View a map of all shelter facilities in the City of Portland and Multnomah County.
Did the Bureau of Planning and Sustainability do any sort of ranking or analysis that indicates the relative value of any specific plot of land?
No. Our analysis was simply to determine how much land was zoned to allow shelters.
What does a typical shelter look like?
The Joint Office operates different shelter systems for families, unaccompanied youths, domestic violence survivors and adults, with more than 1,300 year-round beds. All the shelters are open 24 hours and reservation-based, with people offered beds as long as they need them. That means no one has to line up for a bed at night or leave in the morning. All Joint Office shelters are staffed and supported by experienced nonprofit agencies, providing services on site. Many offer full kitchens and clinic space as well as classrooms, computer labs, office space, laundry, showers, and bathrooms.
Adult shelters in traditional facilities provide bunkbeds, with beds divided into sleeping bays by walls, instead of mats on the ground in large rooms. Alternative shelters offer individual sleeping pods with electricity and heat as well as common spaces such as bathrooms, kitchens, and offices on site. Guests can bring their pets and store their belongings. Couples can sleep next to one another. Secure outdoor space is provided for people to gather and breathe fresh air. In family and domestic violence shelters, families receive their own rooms.
People in all shelters are required to abide by codes of conduct. Shelter providers are expected to attend neighborhood meetings and provide 24-hour points of contact for the community.
Is there any guarantee with this project about the amount and size of shelters allowed within a neighborhood, to ensure that shelters are spread out within a neighborhood?
No, not in the proposed code. The purpose of the project is to remove regulatory barriers to shelter siting. The Joint City/County Office policy is to place shelters where there is a need, and that need is currently citywide. The financial resources to build new shelters are limited (as written above), so that is much more of a limiting factor than zoning. Year-round shelters managed by the Joint Office top out at 120 beds each, a size that makes a space cost-effective to operate while still being small enough to staff and manage successfully.
Are there any guarantees that shelters will be geographically balanced across town?
The track record over the past five years shows that new public shelters have been spread out across the city. That’s because the Joint Office has been working to fill gaps and expand a shelter system that for years was concentrated only downtown and in the central eastside. When asked about how shelter could be easier to access, people with lived experience said having to leave their neighborhood and communities to travel across town was a barrier.
By adding shelters in various areas where there is unmet need, instead of concentrating shelters in any one part of town, whether that’s outer east Portland or downtown, the Joint Office can better meet the community’s needs overall. Four of the eight most recently opened non-COVID-emergency shelters, for example, have been in North, inner Northeast, or Northwest Portland – areas with unmet need and fewer existing services.
Is there any guarantee that particular neighborhoods will not have a disproportionate number of shelters?
The intent of the project was to reduce regulatory barriers. See the answers above for how the Joint Office approaches shelter siting.
How many shelters will be built in the next year or two?
That remains subject to budget and planning decisions shared by the Joint Office of Homeless Services, the City of Portland, and Multnomah County. The Joint Office has built or opened eight new facilities in four years, but most were replacing or expanding existing facilities.
The Joint Office will work this year to convert a former Rite Aid in North Portland’s Arbor Lodge neighborhood into a year-round, long-term shelter. The Joint Office purchased that shelter site in December using federal dollars.
In February, the Joint Office also sought proposals from the community for additional alternative shelter capacity. There is limited funding to match with those proposals, which are due March 9 and will be evaluated to ensure they’ll be successful.
Who will run these facilities? Will there be onsite supervision? What kinds of services/facilities would be included at each site?
Like any other business or program, shelters must be well run to succeed, not just for their neighbors but for their participants. The Joint Office holds its shelter operators to high standards and supports them to ensure their success, resulting in a track record of opening shelters across the community.
There have not been significant issues with crime or other concerns because of these shelters. Some shelters sit on commercial strips. Some are next to residences, near schools and parks. After these shelters have opened, community members have come together to celebrate and support their new neighbors through activities, volunteering, and donations.
The proposed regulations:
- Provide parity between household and group living by allowing group living arrangements by right in the same places that household living is allowed by right.
- Remove code complexity and barriers to the production or retention of group living arrangements.
- Simplify definitions to clarify difference between housing and shelter, group living and household living.
- Eliminate the definition of “household” but continue to regulate residential use as either household living or group living.
What is group living and how is it different from houses or apartments that are rented?
- Most resident uses are classified as household living.
- Group living includes single room occupancy buildings, dorms, retirement care facilities or co-housing complexes where a larger group of residents share kitchens or bathrooms.
- The proposal allows group living by right in residential zones in parity with household living, without a conditional use.
- This increases the range of housing types that can be built. Group living buildings can be more affordable than traditional houses or apartments because kitchens are often the most expensive rooms to build.
What is the difference between group living and single room occupancy living?
The proposed code no longer employs the term “single room occupancy” – or SRO – because it is just a subset or form of group living. Group living is also allowed in buildings that function as apartment buildings, but residents have their own bedrooms and may share bathrooms or kitchens.
Why is there a cap of 3,500 square feet of floor area that applies only to group living?
The cap is a backstop to ensure group living facilities will be similar in size to allowed household living structures on large lots. This cap will not apply to existing buildings, and its application is limited to new group living facilities on oversized, single dwelling, residential lots. It will not apply to normal sized lots or to group living in multi-dwelling residential, mixed use or employment zones. Aside from this cap, all size, height, coverage and bulk regulations for group and household living are exactly the same. This cap is not applied to household living uses because the scale of household living is limited in other ways by density regulations and the number of bedrooms.
Recreational vehicles and tiny houses on wheels
What are recreational vehicles and tiny houses on wheels?
They are vehicles, not buildings. The term is used to refer to campers, motor homes, vacation trailers and fifth-wheel trailers. Tiny homes on wheels and park model recreational vehicles are also included. These are small homes built on a trailer, using a campsite style hook up for water, electricity and sewer. Vehicles are regulated by the Oregon Department of Transportation’s Motor Vehicles Division and are not subject to state and city building codes. The current City code prohibits residential occupancy of vehicles, but enforcement of this prohibition is de-emphasized pending a decision on whether to loosen the prohibition.
Where will recreational vehicles and tiny houses on wheels be allowed?
One recreational vehicle or tiny house on wheels will be allowed on a residential lot as a replacement of an allowed accessory dwelling unit, provided it meets certain industry construction standards. This allowance:
- Acknowledges that many people already live in a recreational vehicles or a tiny house.
- Provides a lower cost option for people who might not be able to afford to rent an accessory dwelling unit, apartment or house.
Recreational vehicles and tiny houses on wheels would also be allowed in outdoor shelters, church parking lots, manufactured home parks and commercial campgrounds.
Why only one recreational vehicle or tiny house on wheels per residential lot?
- Under state law, two or more on any one lot is considered a campground, requiring a state license.
- In Portland, campgrounds or recreational vehicle parks are already allowed in commercial zones.
This one per lot limit does not apply to recreational vehicles and tiny houses on wheels in manufactured home parks.
How will utilities be provided to RVs and tiny houses on wheels?
The proposed code requires that a campground-style utility hookup be installed, with a plug for electricity and connections to City water and sewer.
What City codes other than the Portland Zoning Code are addressed in this project?
- An obsolete chapter of Title 8 of the City code that used to regulate travel trailer courts is repealed because those regulations have been superseded by more current City codes or are pre-empted by state law.
- Two chapters of Title 15 concerning emergency powers are amended to recognize that the city’s shortage of shelter and affordable housing is a continuing – not an episodic – emergency caused by a natural disaster.
- One chapter of Title 17 amends right-of-way regulations to allow mobile support facilities (e.g., mobile showers) adjoining shelters.
- One chapter of Title 29 amends property management regulations to allow permanent residency in a single recreational vehicle or a tiny house on wheels on residential lots and allow accommodations that do not qualify as buildings in outdoor shelters.
Outreach and engagement
Who are the project partner agencies?
- Bureau of Development Services
- Joint Office of Homeless Services
- Office of Management and Finance
- Portland Bureau of Transportation
- Portland Fire and Rescue
- Police Bureau
- City Attorney’s Office
- Mayor Wheeler’s Office
- Commissioner Fritz’s Office
- Commissioner Ryan’s Office
- Commissioner Hardesty’s Office
How was the public engaged before public hearings began?
- Community engagement for S2HC was guided by input from the Community Involvement Committee and the work of a consultant (Angelo Planning).
- Project staff presented the S2HC proposals through video conferencing during a dozen virtual community meetings from May to November, which included people with experience being homeless or living in homeless shelters. More than 90 community members participated.
- Members of a standing inter-agency Housing Continuum Committee participated in these community meetings, answering questions and providing assistance.
- A technical advisory committee drafted the proposals and also participated in community meetings.
- Thirty-one comments were received in response to the Discussion Draft in October. These comments were considered while formulating the Proposed Draft.
How do the changes in the proposed draft of the regulations respond to comments made on the earlier draft?
The Proposed Draft incorporates comments by:
- Increasing the places where shelters are allowed under easier approval procedures.
- Increasing the number of beds and accommodations allowed in some shelters.
- Allowing permanent residential occupancy of recreational vehicles and tiny houses on wheels in some places.
- Providing maps and charts explaining the different shelter allowances.
- Adding numerous technical adjustments.
- Adding a second Planning and Sustainability Commission hearing (on December 15).
The Proposed Draft does not incorporate comments requesting:
- Even greater increases in the number of allowed shelter beds and accommodations.
- Allowing shelters as a permanent use of Open Space after the housing and COVID-19 emergencies expire.
- Allowing permanent residential occupancy of more than one recreational vehicle or tiny house on wheels on a residential lot.
- Stopping or slowing down the project.